RESPONSE TO DEPARTMENT OF HEALTH NORTHERN IRELAND CONSULTATION ON MINIMUM UNIT PRICING OF ALCOHOL IN NORTHERN IRELAND - Alcohol Focus Scotland
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DATE 26/05/2022
RESPONSE TO DEPARTMENT OF HEALTH NORTHERN IRELAND
CONSULTATION ON MINIMUM UNIT PRICING OF ALCOHOL IN NORTHERN
IRELAND
Alcohol Focus Scotland (AFS) is the national charity working to prevent and reduce alcohol harm. We
want to see fewer people have their health damaged or lives cut short due to alcohol, fewer children
and families suffering as a result of other people’s drinking, and communities free from alcohol-related
crime and violence. AFS welcomes the opportunity to respond to the Department of Health Northern
Ireland consultation on the introduction of minimum unit pricing for alcohol products.
Summary
• AFS supports Northern Ireland’s aim of introducing MUP to reduce alcohol harms.
• AFS also supports banning promotions such as multi-buy discounts.
• The WHO and the OECD identify pricing policies such as MUP as being the most effective
way of reducing alcohol harms.
• There is a growing body of evidence demonstrating MUP’s effectiveness, including data from
Scotland.
• MUP should be set to at least 65p per unit.
• MUP should be index-linked from its conception, e.g. to the Retail Price Index, to prevent
future erosion of its impact due to inflation.
Q1: Do you agree with the overall policy aim of reducing the harm alcohol causes?
Strongly Agree
Alcohol Focus Scotland is the national charity working to prevent and reduce alcohol harm in
Scotland. We also collaborate with international partners to promote and advocate for effective
alcohol harm prevention policy measures around the world. We believe that a Global Framework
Convention on Alcohol Control should be developed to better support countries seeking to reduce
the burden of alcohol harm. We want to see fewer people have their health damaged or lives cut
short due to alcohol, fewer children and families suffering as a result of other people's drinking, and
communities free from alcohol-related crime and violence.
As outlined in the consultation document and made apparent through international evidence,
alcohol use contributes to significant harms, not only to individuals but to those nearest to them
such as family and friends, as well as to the wider communities in which they live.
Northern Ireland, like Scotland, lacks all the devolved competencies necessary to implement all the
World Health Organization’s (WHO) most cost-effective interventions to reduce alcohol related
public health harm.1 However, Northern Ireland has the power to raise prices on alcohol through
excise taxes and pricing policies, such as MUP.
Alcohol Focus Scotland
Registered Scottish Charity (SC009538)
A Company Limited by Guarantee (Scottish Company No. SC094096).DATE 26/05/2022
Q2: Do you believe that introducing MUP for alcohol into Northern Ireland will have an impact on
reducing alcohol-related harm?
Strongly Agree
Pricing policies have been identified by the WHO as having the strongest evidence of success in
impacting on alcohol consumption and alcohol-related harm.2 The OECD’s 2021 publication
“Preventing Harmful Alcohol Use” also highlights that “Alcohol pricing is a key method used to
reduce consumption”.3 The chapter notes that “Empirical research evaluating MUP, to date, has
found promising results”, presenting examples from:
• Canada: British Columbia, Manitoba, Newfoundland, Nova Scotia, and Quebec
• The United Kingdom: Scotland and Wales
• Outside the OECD: the Russian Federation, Ukraine, the Republic of Moldova, and
Uzbekistan
Scotland was the first country to implement MUP on 1 May 2018. MUP in Scotland primarily
affected the cheapest alcoholic products, such as strong white cider, own brand vodka and gin, and
super-strength lager,4 the products favoured by the heaviest drinkers at most risk of harm.5
The Scottish Government appointed Public Health Scotland (PHS) to lead a rigorous five-year,
multi-project evaluation of MUP in Scotland.6
So far, evidence has shown that, in the first full two years after its implementation, MUP had the
intended effect of reducing consumption. In the first full year after the policy’s implementation, we
also saw encouraging early signs that this reduction was beginning to translate into health benefits.
Amongst the benefits of MUP identified by PHS and others in evaluation studies so far are:
• A 3.5% reduction in off-trade sales per adult in the first year of MUP.7
• Reductions in household alcohol expenditure, particularly in households that bought the
most alcohol before MUP.8 9
• The volume of pure alcohol sold per adult in Scotland in 2020 was 9.4 litres; the lowest level
in 26 years.10
• A 10% reduction in alcohol-specific deaths in the first full year after the introduction of MUP;
the lowest level since 2013.11
• A small reduction in hospital admissions from liver disease in each of the first two years of
MUP.12
• Reduction in consumption of cheap, high-strength products related to harmful drinking.13 14
• High levels of compliance with MUP by retailers15 and no significant negative impacts on
alcohol producers or sellers.14 16
Q3: Do you foresee the introduction of MUP into Northern Ireland as impacting negatively
upon any specific groups?
No
The alcohol and hospitality industries will likely demonstrate some resistance to the implementation
of MUP. However, evidence has shown that despite a reduction in the volume of sales, the off-trade
will experience a modest financial increase due to MUP. On-trade premises will not be negatively
affected, as their retail price of alcohol reflects other variables such as staffing. In fact, off-trade
Alcohol Focus Scotland
Registered Scottish Charity (SC009538)
A Company Limited by Guarantee (Scottish Company No. SC094096).DATE 26/05/2022
alcohol tends to be cheaper than on-trade alcohol, so MUP will help balance prices overall. There
have been no widespread negative impacts for industry or retailers.
As outlined by the original Sheffield Modelling,5 the people most impacted by MUP will be and have
been people drinking at harmful or hazardous levels, not dependent drinkers. The distinction is
noteworthy as MUP intends to decrease the drinking of people at risk of developing alcohol
dependency. MUP has had the intended effect of reducing consumption for these groups, without
any common negative effects.
A recent study has also found that after MUP was introduced, the proportion of people with alcohol
dependence drinking alcohol at less than 50p per unit reduced substantially.17 The same study found
evidence that some people with alcohol dependence reduced expenditure on other items due to
spending more on alcohol.
A study on homeless and street drinkers suggested that more joined up working and information for
support services could be beneficial around the time of MUP implementation.18
Overall, support for MUP in Scotland has grown over time.19 It is likely that the same will happen in
Northern Ireland.
Q4: Do you believe that of the pricing options considered, that MUP for alcohol is the most
effective way of achieving the policy aim of reducing harm? Are there other pricing policy
options that should have been considered?
Yes
Of the options considered, MUP is the most effective way of reducing consumption and subsequent
harms. There is growing evidence in support of the effectiveness of MUP, both in Scotland (see our
response to Q2) and internationally. For instance, evidence from Canada and the Northern Territory
of Australia has shown that the policy is effective in reducing alcohol-related deaths and hospital
admissions and in reducing consumption rates.20 21 22 23
AFS also supports banning promotions. The Alcohol etc. (Scotland) Act 2010 restricts the supply of
alcoholic drinks free of charge or at a reduced price, including promotions such as “buy one, get one
free” and “3 bottles of wine for £10”.24 Modelling undertaken prior to the implementation of the
multi-buy discount ban in Scotland estimated that banning all off-trade price promotions (both
quantity discounts and other price-based promotions) could deliver a reduction in alcohol
consumption of 3.1% and would complement minimum unit pricing.25 The quantity discount ban
which was implemented in Scotland in 2011 was more limited in scope and did not prevent straight
price discounting. Nevertheless, research undertaken as part of the Monitoring and Evaluating
Scotland’s Alcohol Strategy (MESAS) found it had delivered a reduction in off-sales of 2.6%,26 largely
driven by a reduction in sales of wine. Despite this, the researchers were told that retailers had
responded to the multi-buy discount by enhancing other promotions and they found an average of
50% of all off-trade alcohol sales in Scotland in the 12-month period after the ban was introduced
had been on promotion. They concluded “that the estimated impact of the Alcohol Act described in
this report may have been larger if a total ban on off-trade discounting was introduced.”
Q5: Do you have any opinion on the level on which MUP should be set initially and why?
65p
Alcohol Focus Scotland
Registered Scottish Charity (SC009538)
A Company Limited by Guarantee (Scottish Company No. SC094096).DATE 26/05/2022
MUP in Scotland was set at 50p per unit of alcohol. This was agreed on in 2012 but following a
lengthy set of legal challenges from the alcohol industry which were eventually overruled, its
implementation was delayed by 6 years.
From 2012 to 2018, and to 2022, inflation has likely eroded the effect of the current 50p per unit.
Based on the retail price index, a minimum unit price of 50p in 2012 is equivalent to 61p in 2021.
Therefore, the proportion of alcohol products affected by MUP has significantly reduced. The
proportion of off-trade alcohol units sold below 50ppu dropped from 60% in 201227 when the
Scottish Parliament passed the Alcohol (Minimum Pricing) Act, to 44% in 201828 when MUP was
introduced. This drop means a decline both in the proportion of products affected by the policy and
the price increase imposed on each affected product. This effect appears to have continued since
implementation, with data for England and Wales showing that just 34% of off-trade alcohol units
were sold below 50ppu in 2020.10
However, making good on inflation is not enough when alcohol harms remain so high, especially
considering the Covid-19 pandemic which saw many of us, especially those already drinking at
higher levels, increase our drinking. In 2016, modelling from the University of Sheffield estimated
that a minimum unit price of 60p per unit would deliver double the reduction in deaths and hospital
admissions, while 70p would deliver three times the effect.5
For these reasons, AFS and 29 other leading health charities in Scotland have called for MUP to be
uprated to at least 65p per unit.29
In order to prevent future erosion of the impact of MUP due to inflation, we recommend that the
price should be index-linked, e.g. to the Retail Price Index. This will ensure that MUP continues to
reduce harm and save lives.
Q6: Do you agree that the level of the MUP should be varied over time? If so, what other
information or evidence do you think should be considered when amending the MUP?
Yes
As outlined above in Q5, we recommend that the price should be index-linked from its conception,
e.g. to the Retail Price Index, to prevent future erosion of the impact of MUP due to inflation.
Q7: If the MUP rate is to be varied over time, what do you believe would be the best method
of achieving this?
Varied by Regular Uplift
Of the options presented in the consultation document, AFS prefers the second option, whereby the
Health Minister sets the initial level of MUP but it automatically varies each year by an appropriate
measure of inflation. An annual review mechanism, and linking MUP to inflation would protect
against erosion of the impact of the policy. A regular date of change would be beneficial, as
businesses would be able to plan ahead.
Ideally, we would prefer to see a combination of both an index-linked mechanism to ensure the
policy keeps pace with inflation, and a regular review by the Department of Health to assess the
efficacy of the policy. This would serve the dual purpose of sustaining the policy’s impact on the
affordability of alcohol and enabling adjustment of the MUP to optimise the health benefits of the
policy.
Alcohol Focus Scotland
Registered Scottish Charity (SC009538)
A Company Limited by Guarantee (Scottish Company No. SC094096).DATE 26/05/2022
There is currently no mechanism to review the MUP in Scotland. AFS is advocating for the inclusion
of an index-linked method alongside a regular review mechanism based on health and harm
outcomes to be introduced going forward in Scotland.
Q8: Do you agree with the use of the formula for setting the total Minimum price for a
product?
Yes
The same formula is in use in Scotland, Wales, and Jersey. It is easily understood and its
implementation has proven practical.
Q9: Do you agree with the enforcement proposals and sanctions that would be added to the
necessary legislation?
Yes
Meaningful sanctions are often necessary to ensure compliance, deterring economic actors from
attempting to find loopholes in the legislation. However, genuine errors are possible, and we would
recommend option b) to follow option a) only if the offence is repeated.
Q10: Do you agree with the proposed targets and monitoring arrangements?
Yes
We would also propose considering monitoring:
• Rates of alcohol use per adult
• Percentage of children and young people under the age of 18 using alcohol, both in the last
30 days and ever
• Percentage of children where parental alcohol use was identified as a concern on the child
protection register
Q11: Do you agree with the outcome of the Impact Assessment Screenings? Have you any
comments on either the Equality/Good Relations or Rural screening documents? Is there anything you
believe we should be considering in future Equality/Good Relations or Rural screenings or future
impact assessments?
Neither Agree nor Disagree
NA
Q12: Do you agree with the outcome of the Regulatory Impact Assessment? Have you any
comments on the Regulatory Impact Assessment? Is there anything you believe we should be
considering in future regulatory impact assessments?
Neither Agree nor Disagree
NA
Alcohol Focus Scotland
Registered Scottish Charity (SC009538)
A Company Limited by Guarantee (Scottish Company No. SC094096).DATE 26/05/2022
References
1
World Health Organization (2018). The SAFER initiative: A world free from alcohol related harm. Available at:
https://www.who.int/initiatives/SAFER
2
World Health Organization (2018). The SAFER initiative: Pricing policies. Available at:
https://www.who.int/initiatives/SAFER/pricing-policies
3
OECD (2021). Preventing Harmful Alcohol Use. Available at: https://www.oecd.org/publications/preventing-
harmful-alcohol-use-6e4b4ffb-en.htm
4
Alcohol Focus Scotland (2016). Scottish Alcohol Price Survey 2016. Glasgow: Alcohol Focus Scotland. Available
at: http://www.alcohol-focus-scotland.org.uk/media/152485/Scottish-price-check-2016.pdf
5
Angus, C., Holmes, J., Pryce, R., Meier, P. & Brennan, P. (2016). Model-based appraisal of the comparative
impact of Minimum Unit Pricing and taxation policies in Scotland. An adaptation of the Sheffield Alcohol Policy
Model version 3. ScHARR, University of Sheffield. Available at:
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6
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evaluation-of-mup/why-we-are-evaluating-mup
7
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12
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13
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14
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15
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Alcohol Focus Scotland
Registered Scottish Charity (SC009538)
A Company Limited by Guarantee (Scottish Company No. SC094096).DATE 26/05/2022
http://www.healthscotland.scot/media/2660/minimum-unit-pricing-for-alcohol-evaluation-compliance-study-
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17
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18
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Whittaker A (2022). Minimum Unit Pricing: Qualitative Study of the Experiences of Homeless Drinkers, Street
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19
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20
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21
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22
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23
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24
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26
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27
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28
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29
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